Supplier Responsibility Expectations

3M values supplier partnerships where our core values align with empowering ethical growth, inspiring integrity through collaboration and compliance, as well as stewardship of our people, planet and practices. We encourage all suppliers to have a proactive approach in aligning with 3M's policies and programs to strengthen our supply chains and ensure conformance to regulations. By working together, we can achieve business success and uphold our strong, positive reputations.

It is the responsibility of 3M Suppliers to stay current on applicable laws.

ALERT for All Suppliers: U.S. Customs and Border Protection Legislation; North Korean Labor:

3M, as an importer into the United States, is required to comply with U.S. Customs and Border Protection (CBP) laws and regulations. CBP published the Countering America’s Adversaries Through Sanctions Act (CAATSA) in August 2017. CAATSA prohibits importation under 19 U.S.C. 1307 into the U.S. of goods produced wholly or in part with North Korean labor.

Background: The 3M “Supply Chain Policies” were first established in 2006 to document our expectations for suppliers’ environmental, health, safety, labor and transportation performance. The Supplier Responsibility Code is the “next generation” of our expectations for supplier responsible practices.

Why this, why now? Over the past decade, expectations for corporations to apply responsible sourcing practices to their supplier network have been expanding in scope and detail. Our foundational requirements for our suppliers must mature to meet these expectations. In addition, 3M became a signatory to the UN Global Compact in early 2014, and this updated set of expectations for our suppliers aligns with the UN Global Compact 10 principles.

How was this new version developed? A cross-functional team benchmarked the supplier requirements from many peer companies (multi-national manufacturers of diverse products). We also consulted guidance from organizations like the OECD and the UN, and recent case studies from consulting firms and not-for-profit sustainability organizations. Most significantly, we used as a basis for this draft the Electronics Industry Citizenship Coalition (EICC) Code of Conduct, tailoring it to include important aspects of 3M’s existing Supply Chain Policies. The EICC Code is a well-established, comprehensive Code that is pervasive in the electronics industry, and is increasingly being emulated in other industries.

What does it cover? This 3M Supplier Responsibility Code consists of 5 main sections, with some of the more significant updates to our original Policies noted below:

Labor – includes more specific requirements and controls for the elimination of forced labor, and more details on appropriate working hours and time off.

Environment – includes expectations on reducing environmental impacts, and protecting air, water, and land resources.

Ethics – this is a new section, mirroring 3M’s Code of Conduct positions on anti-bribery, conflicts of interest, protection of intellectual property, and related Business Conduct issues.

Management Systems – another new section, requiring strong policies and systems to control the aspects in the previous sections, and propagate the requirements up the supply chain.

How will we implement? New and renegotiated supply contracts and PO terms will reference the new code. Existing contracts will not be re-negotiated solely for this change. Our supplier assessment program is being updated to match the Code expectations.

Background. Armed groups operating in the eastern Democratic Republic of the Congo (DRC) have controlled many of the region’s mines or transit routes and have engaged in armed conflict, as well as some of the world's worst human rights violations. Concern that proceeds from the mining of minerals have been used to fund extreme violence in that region led to a requirement in the U.S. Dodd-Frank Financial Reform Law of 2010, that U.S. publicly-traded companies must disclose any "conflict minerals" necessary to the functionality or production of products they manufacture or contract to manufacture. The conflict minerals are tin, tungsten, tantalum and gold (called the 3TG's). Companies using conflict minerals must also disclose their supply chain inquiries to verify whether these minerals originated in the DRC or adjoining countries.

On August 22, 2012, the SEC approved the final rule on conflict minerals. All public companies must evaluate their product lines to determine whether they contain necessary conflict minerals and if so, file a Form SD by May 31 annually beginning in 2014, for products they manufacture or contract to manufacture in the year 2013. While the burden of compliance is on the public companies who manufacture those products, members of their supply chains for those products are also impacted.

Background
3M is a worldwide leader in innovation and quality. To deliver best value, cutting edge products, 3M maintains a dynamic, worldwide supply chain. As with any global supply chain, there is risk that counterfeit materials, parts, components and assemblies may be introduced. The presence of counterfeit material could adversely impact 3M’s ability to meet customer expectations and expose 3M to penalties, fines, damages and other serious adverse consequences. Accordingly, 3M has established a Counterfeit Material Control Plan to ensure compliance with customer anti-counterfeit requirements, the evolving laws in this area and to ensure the overall quality, compliance and reputation of 3M’s diverse, innovative product lines.

3M Expectations of Suppliers
As part of 3M’s Counterfeit Material Control Plan, 3M has implemented a minimum set of risk-based counterfeit mitigation measures for all product lines, including measures relating to products and materials provided to 3M by suppliers. These measures are reflected in the Counterfeit Goods Provisions referenced below and are in addition to any other counterfeit goods requirements specified in a written agreement with 3M or provided to a supplier by 3M.

Counterfeit Goods Provisions
The following provisions apply to any purchase order for goods issued by 3M Company or its affiliates and to products provided to 3M or its affiliates pursuant to a written agreement:

3M is committed to respect for human rights in our own operations, in any business that works on our behalf, and in our supply chain. Our global Human Rights Policy applies to all 3M employees, contingent workers, anyone doing business with or on behalf of 3M, and candidates for hire at 3M. In addition, 3M expects its suppliers to be in full compliance with all applicable labor and human resource laws, committed to upholding the human rights of workers, and treating them with dignity and respect as understood by the international community and as stated in our Supplier Responsibility Code.

In 2014, 3M became a signatory member of the United Nations Global Compact (UNGC), thereby committing to align our operations and strategies with the UNGC principles on human rights. Our global Human Rights Policy contains our prohibition on human trafficking. We are committed to using effective systems and controls to prevent human trafficking from taking place anywhere within our business or supply chains. The prohibitions apply to 3M and its subsidiaries, our federal contracts and subcontracts for either commercial or non-commercial items, and all of 3M’s global suppliers.

The California Transparency in Supply Chains Act of 2010 (SB 657) and the UK Modern Slavery Act 2015 require certain businesses to produce a statement setting out the steps they have taken to ensure there is no modern slavery in their own business and their supply chains. Recent disclosure statements 3M has issued can be found below.

Forests are used by people around the world for recreation, cultural significance, health and livelihood. They are home to many species of plants and animals, their trees capture and store atmospheric carbon, and they support vital services like clean water. These complex ecosystems are valuable resources that should be responsibly managed and preserved for future generations. 3M does not support natural forest degradation or conversion to non-forest use. We support the protection of indigenous peoples’ rights to offer Free and Prior Informed Consent (FPIC) to harvesting operations on their land, and of workers’ safety and other basic rights.

At 3M, we are guided by our values; they are woven into the very fabric of our company culture. We act with uncompromising integrity. We respect our social and physical environments around the world. We share our sustainability values with our customers and stakeholders. 3M wants to work with the best suppliers who share these commitments to sustainable forests and responsibility in all stages of the forest products supply chain.

We expect our pulp and paper suppliers to read, understand and implement the
expectations in our Policy. The companion PDF DocumentPolicy Conformance Guidance
Document (206.57 KB)
contains definitions and additional explanation of many of the important
concepts in the Policy. 3M will also provide our suppliers additional
information and opportunities for education and engagement.

We encourage you to watch this
video message from 3M's Vice President of Sourcing and Chief Sustainability Officer on your role as a supplier in working with 3M to advance sustainable forestry around the globe.

Please refer to 3M's web page on Sustainable Forestry for more information, including links to our semi-annual Policy Progress Reports.

3M’s Expectations for Suppliers

Legality: 3M expects that all pulp, paper and packaging supplied to us contains wood or plant-based fiber that is legally harvested, sourced, transported and exported from its country of origin. Please see the Legal Harvesting Laws on this page for more information on these expectations.

Traceable to Forest Source: 3M expects suppliers to know their own supply chains, and respond to our requests for material traceability information in a complete and timely manner. Understanding our forest products supply chain, including paper and pulp mills and forest sources, is fundamental to ensuring Policy conformance. We depend on our direct suppliers to understand and disclose their supply chains to us, so that together we can ensure Policy conformance and drive responsible sourcing and sustainable forestry.

Due Diligence Management System: 3M expects our suppliers to adopt company policies and a due diligence management system approach to address responsible forest products sourcing and sustainable forestry. We also expect our suppliers to work with their suppliers to adopt similar policies and management systems. 3M has created a
Word Documentdue diligence management system template outline (60 KB) for our suppliers' use if they choose, and which can be shared with their suppliers.

Certification: 3M expects our suppliers to know the forest certification status of the material they purchase and of the entities in their supply chain, and to disclose certification information to us upon request. 3M’s policy expectations and guidelines are consistent with many forest certification standards, but our Policy does not require certification. Certification in and of itself is not the objective of our Policy, but it is one useful tool to help verify what is happening on the ground. Please refer to this
PDF Documentforestry certification overview (513 KB) for more on how we believe our Policy compares to the major global forestry certification schemes.

Collaboration: 3M expects our suppliers to work together with us and their suppliers to ensure Policy conformance and promote responsible and transparent supply chains. We recognize the integral role that our suppliers play to source and produce the materials required for 3M products, and we know that collaboration and transparency depend on a foundation of mutual trust. Through our Pulp & Paper Sourcing Policy, we wish to harness the power of our supply chain to achieve real, positive change for the world's forests.

Conformance: 3M expects our suppliers to be forthcoming in their opportunities for performance improvements for themselves or their suppliers, and in cases where conformance cannot immediately be demonstrated, we will support suppliers that are working on timely and reasonable progress towards conformance. If a supplier won’t work with us or change their practices to conform, 3M will seek alternative sources of supply.

Refer to this PDF Documentpresentation (2.3 MB) for additional information on the 3M Pulp and Paper Sourcing Policy.

How Policy Conformance Benefits 3M Suppliers

The business climate is continually changing and evolving. Not only are
more customers interested in understanding where their products come from,
but governments around the world, through laws and regulations, are
requiring product producers to know more about the sources of their raw
materials. Products that can be traced to responsible sources will help your
business comply with regulations and protect your reputation, and can be a
differentiation factor in retaining existing business and earning
opportunities for new business.

Together, we can support sustainable forestry and responsible,
transparent supply chains.

Products and product packaging supplied to 3M Company must comply with laws related to product content, including laws that prohibit use of illegally harvested timber or plant materials. Laws regarding timber and timber products, such as the United States Lacey Act, the European Union Timber Regulation, and the Australia Illegal Logging Prohibition Act, restrict the sales and imports of illegally harvested timber or products derived from such timber (including paper or paper pulp). These laws also may include "due care" or "due diligence" requirements.

Additional Details on U.S. Lacey Act Requirements

The U.S. Lacey Act was amended in 2008 to prohibit the purchase or sale of products or product packaging in the United States made from wood, paper, wood fiber or other plant materials, with certain limited exceptions, if the plant material was illegally harvested in its country of origin. The Lacey Act has import declaration requirements that are currently in effect for a limited number of wood products. However, the prohibition on purchase or sale of products containing illegally harvested plant materials applies to all products containing plant material.

3M has developed a corporate U.S. Lacey Act Specification. The Specification has additional background on this law, and sets out 3M's expectations for suppliers providing materials to 3M that contain plant material subject to the Lacey Act. See U.S. Lacey Act Specification.

3M includes prohibitions on illegally harvested plant materials in new and renewed sourcing contracts. Under 3M's Supplier Responsibility Code and previously 3M's Supply Chain Policies: EHS, Transportation, Labor/Human Resources and Supplied Materials, suppliers are expected to supply 3M materials containing plant materials or their derivatives that are legally sourced, harvested and exported from their country of origin. Suppliers are also expected to adopt policies and management systems with respect to the United States Lacey Act, the European Union Timber Regulation and similar laws (such as the Australia Illegal Logging Prohibition Act), and to require their suppliers to adopt similar policies and systems.

As a supplier to 3M, please become aware of these requirements and take the following steps:

Determine which of the products you supply to 3M contain timber or plant materials within the scope of the U.S. Lacey Act, the EU Timber Regulation, Australia Illegal Logging Act and similar laws.

Work with your suppliers to make sure all plant materials are legally harvested, sourced and exported from their country of origin, or validate the origin as recycled.

Adopt company policies and management systems with respect to the U.S. Lacey Act, EU Timber Regulation, Australia Illegal Logging Act and similar laws, and require your suppliers to adopt similar policies and systems. This will assist in pushing these requirements upstream and in obtaining information on legality of harvest that is passed downstream.

California's Rigid Plastic Packaging Container (RPPC) law was enacted in 1991 as part of an effort to reduce the amount of plastic waste disposed in California landfills and to increase the use of recycled postconsumer plastic. The law mandates that product manufacturers that sell products held in RPPCs meet one of the compliance options identified in the regulation.

3M is committed to compliance with all laws, including those relating to Rigid Plastic Packaging Container (RPPC). RPPC generally means a packaging container that:

is made entirely of plastic (except for incidental portions of the packaging),

has a relatively inflexible shape or form,

has a minimum capacity or volume of eight (8) ounces up to a maximum capacity or volume of five (5) gallons,

is capable of at least one closure (including closure during the manufacturing process).

RPPCs can range in shape, color, size, and form. RPPCs can include, but are not limited to:

Buckets

Tubs

Pails

Tubes

Cartridges

Jugs

Bottles (wide mouth and/or narrow neck)

Clamshells (heat-sealed and/or reclosable)

Plastic Folding Cartons

RPPC legislation requires Packaging component suppliers to provide Certificates of Compliance with California law as required by Title 14 of the California Code of Regulations. We are requesting that as a supplier to 3M you provide all Container Manufacturer Certification Information as required under Section 17945.4 of Title 14, California Code of Regulations (CCR) for the package component numbers provided.

We are sure that your company, like 3M, is committed to compliance with all applicable laws.

3M Company has developed a corporate EU RoHS Specification which sets forth 3M's expectations for suppliers providing materials to 3M that may be subject to the requirements of Annex II of the European Union Directive 2011/65/EU on the restriction of the use of certain hazardous substances in electrical and electronic equipment, as amended by Commission Delegated Directive (EU) 2015/863, known as "EU RoHS."

Under EU RoHS, electrical and electronic equipment placed on the European Union market may not contain more than certain levels of:

Lead

Mercury

Cadmium

Hexavalent Chromium

Polybrominated biphenyls (PBBs) (flame retardant)

Polybrominated diphenyl ethers (PBDEs) (flame retardant)

Bis(2-ethylhexyl) phthalate (DEHP)*

Butyl benzyl phthalate (BBP)*

Dibutyl phthalate (DBP)*

Diisobutyl phthalate (DIBP)*

Other countries around the world are considering and/or have implemented regulations that are similar to EU RoHS.

The 3M EU RoHS Specification applies to all materials, parts, components and/or products (whether finished or semi-finished) that include restrictions on the EU RoHS substances listed above or that have this specification cited on or in their 3M part number drawing, part or product specifications, sourcing agreements, purchase contracts, purchase orders or other purchasing documentation.

(*) – Restriction of final products placed on the EU market containing these substances does not enter into force for EEE Category 1-7, 10 & 11 until July 22, 2019 and until July 22, 2021 for Category 8 & 9 products. However, to allow time for parts/products to permeate through the supply chain which must meet these timelines when they are to be placed on the EU market, 3M still expects suppliers to meet this specification.